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Terrorist Financing and the Internet

Michael Jacobsona
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Stein Program on Counterterrorism and Intelligence, The Washington Institute for Near East Policy,
Washington, DC, USA
Online publication date: 09 March 2010

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Studies in Conflict & Terrorism, 33:353363, 2010

Copyright Taylor & Francis Group, LLC
ISSN: 1057-610X print / 1521-0731 online
DOI: 10.1080/10576101003587184

Terrorist Financing and the Internet

MICHAEL JACOBSON

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Stein Program on Counterterrorism and Intelligence

The Washington Institute for Near East Policy
Washington, DC, USA
While al Qaeda has used the Internet primarily to spread its propaganda and to rally new
recruits, the terrorist group has also relied on the Internet for financing-related purposes.
Other Islamist terrorist groups, including Hamas, Lashkar e-Taiba, and Hizballah
have also made extensive use of the Internet to raise and transfer needed funds to
support their activities. The Internets appeal in this regard for terrorist groups is
readily apparentoffering a broad reach, timely efficiency, as well as a certain degree
of anonymity and security for both donors and recipients. Unfortunately, while many
governments now recognize that the Internet is an increasingly valuable tool for terrorist
organizations, the response to this point has been inconsistent. For the U.S. and its allies
to effectively counter this dangerous trend, they will have to prioritize their efforts in
this area in the years to come.

As Al Qaeda has come under growing international pressure, the terrorist organization
has increasingly relied on the Internet to spread its toxic message and drum up support
throughout the world. While its use of the Internet for propaganda and recruiting purposes
has received wide publicity, Al Qaeda has also utilized the Internet for a variety of other
purposes, including terrorist financing. Al Qaeda is far from alone among terrorist organizations in exploiting the Internet for this type of activity. A wide range of other terrorist
groups, including Hamas, Lashkar e-Taiba, and Hizballah have also made extensive use of
the Internet to raise and transfer needed funds to support their activities. It is not difficult
to understand the appeal of the Internet in this area, as it offers a broad reach, timely efficiency, as well as a certain degree of anonymity and security for both donors and recipients.
Unfortunately, while governments throughout the world now recognize that the Internet is
an increasingly valuable tool for terrorist organizations, the response to this point has been
inconsistent. For the United States and its allies to effectively counter this dangerous trend,
they will have to prioritize their efforts in this area in the years to come.

Terrorists Early Use of the Internet

While terrorists use of the Internet for finance-related activities dramatically increased
after 9/11, it began well before this. Of course, in many cases, the U.S. government and the
general public only learned about these early activities after the 11 September 2001 attacks,
Received 15 June 2009; accepted 2 July 2009.
Address correspondence to Michael Jacobson, Senior Fellow, Stein Program on Counterterrorism
and Intelligence, The Washington Institute for Near East Policy, 1828 L Street NW Suite 1050,
Washington, DC 20036, USA. E-mail: mjacobson@msn.com

353

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M. Jacobson

when investigative efforts were dramatically stepped up. The most prominent example was
Babar Ahmad, a young British citizen from South London, who put his computer expertise
to use early on in support of the jihadist cause.1 Beginning in 1997, Babar ran an entity
called Azzam Publications and a number of associated websites, which were primarily
focused on supporting the Taliban in Afghanistan and the mujahidin in Chechnya. On
these sites, Babar solicited funds, attempted to recruit fighters, and even provided detailed
instructions on how individuals could get both themselves and money to these conflict
zones.2 The website was quite explicit on its purpose. On a question and answer page,
Babar wrote that Azzam Publications has been set up to propagate the call for Jihad
among the Muslims who are sitting down, ignorant of this vital duty. . . . Thus the purpose
of Azzam Publications is to incite the believers and secondly to raise some money for the
brothers. Babar was arrested in 2004 by the United Kingdom, on the basis of an extradition
request by the United States. Babars appeals of the extradition request are still currently
pending.3
To persuade individuals to donate, Babar used a familiar argument on his websitethat
supporting the jihad in some fashion was an obligation incumbent upon every Muslim.
Babar noted that even if an individual could not go fight in the jihad, he nonetheless had a
religious obligation to contribute funds, writing that the [f]irst and most important thing
that Muslims can do in the West is to donate money and to raise it amongst their families,
friends and others . . . jihad is a profitable investment that pays handsome dividends. For
someone who is not able to fight at this moment in time due to a valid excuse they can start
by the collection and donation of funds.4
Sami al-Hussayen, a Saudi graduate student at Idaho State University, also served
as the webmaster for a series of extremist websites before 9/11. These included the site
of al-Haramain, a Saudi-based nongovernmental organization (NGO) later designated by
the U.S. Treasury Department for its ties to Al Qaeda.5 Speeches and lectures promoting
violent jihad in Israel were also one of the focuses of these sites. Of particular note, the
websites included a special by invitation only discussion group where participants were
urged to contribute funds to to assist their brothers in their honorable jihad against the
dictatorial Zionist Jewish entity. Al-Hussayen was indicted in 2003 for providing support
to Hamas, with the government alleging that al-Hussayen knew and intended that his
computer expertise and services would be used to recruit and to raise funds for violent
jihad in Israel, Chechnya and elsewhere and that he conspired to conceal the nature of
his activities.6 Al-Hussayen was eventually acquitted of these charges by an Idaho jury.7
The jury appeared to buy al-Hussayens defense that he should not be held responsible for
the material on the website, regardless of how disturbing it might be. As al-Hussayens
attorney argued, These are not Samis opinions. Its not right to hold him responsible for
what someone else said.8 Leaving the merits of the legal case against al-Hussayen aside,
the material the prosecution presented during the course of the trial does illustrate what
was available in cyberspace, even before 9/11.

Growing Exploitation of the Internet Post-9/11

Since 9/11, terrorist groups have made increasing use of the Internet to further their organizations goals and activities. Most of the activity on the Internet has revolved around
propaganda, recruiting, and training, as terrorist groups have taken advantage of the vast
and growing reach of the Internet to all corners of the world. Indeed, the number of websites
associated with Al Qaeda has increased from 12 in 1998 to approximately 2,600 by 2006,
according to a UN study. Many different terrorist groups have had websites or made active

Terrorist Financing and the Internet

355

use of the Internet at one point or another including Al Qaeda, Al Qaeda in Iraq, Laskhar
e-Taiba, Chechen mujahidin,9 as well as the Palestinian rejectionist groups.10 As terrorists
have turned to the Internet to spread their messages and to try to attract new recruits, they
have also turned to the Internet for financing-related activities, such as raising and transferring funds needed to sustain the organizations. This was a trend the U.S. government
predicted in a 2006 National Intelligence Estimate (NIE). The NIE warned that groups of
all stripes will increasingly use the Internet to obtain logistical and financial support. The
report noted, more generally, that technology and globalization have also enabled small
groups of alienated people not only to connect but to raise resources for attacks without
need for an established terrorist organization.11

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Criminal Activity on the Internet

One of the primary ways that terrorist groups are using the Internet to raise funds is through
criminal activity. Younis Tsouli, a young British man better known by his Internet code
name Irhabi 007 (translated as Terrorist 007) may today be the best known virtual
terrorist. As Evan Kohlman, a well-known terrorism expert observed, Over the space of
only two years, he became the undisputed king of internet terrorism.12 Tsouli began his
career by posting videos depicting terrorist activity on various websites. He came to
the attention of Al Qaeda in Iraq (AQI), whose leaders were impressed by his computer
knowledge and his ambitiousness, and quickly developed close ties to this organization.
Once he proved his bona fides, AQI began feeding videos directly to Tsouli for him to post.13
At the outset, Tsouli put these videos on free webhosting services, and at this point he had
few expenses and little need for funds. However, these free sites had limited bandwidth and
soon came to slow Tsouli down as he ramped up his activities. Tsouli then turned to sites
with better technical capabilities, but which also cost money.14
Not surprisingly, given his expertise, Tsouli turned to the Internet to raise the money
to pay for these sites. Tsouli and his partnerTariq al-Daourbegan acquiring stolen
credit card numbers on the Web, purchasing them through various online forums, such as
Cardplanet.15 By the time Tsouli and his partner were arrested, al-Daour had accumulated
37,000 stolen credit card numbers on his computerwhich they had used to make more
than $3.5 million in charges.16 Tsouli laundered money through a number of online gambling sites, such as absolutepoker.com and paradisepoker.com, using the stolen credit card
information, conducting hundreds of transactions at 43 different sites in all. Any winnings
would be cashed in and transferred electronically to bank accounts specifically established
for this purpose. In this way, the money would now appear legitimately won, and thus
successfully laundered.17 In total, Tsouli used 72 of these credit cards to register 180 websites, which were hosted by 95 different companies.18 Tsouli also used these credit cards
to purchase equipment for the mujahidin, by having it sent to sites or premises that he and
his associate would rent on a short-term basis.

Charities
Charities and NGOs remain a major problem in the terrorist financing arena, and their
activities on the Internet are no exception to this troublesome trend. According to the Parisbased Financial Action Task Force, the misuse of non-profit organizations for the financing
of terrorism is coming to be recognized as a crucial weak point in the global struggle to
stop such funding at its source.19 Charities are especially susceptible to abuse by terrorists
and their supporters for whom charitable or humanitarian organizations are particularly

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M. Jacobson

attractive front organizations. Indeed, terrorist groups have long exploited charities for a
variety of purposes. Some charities are founded with the express purpose of financing terror,
while others are existing entities that are infiltrated by terrorist operatives and supporters
and co-opted from within. A particularly serious challenge not only for law enforcement
and intelligence officials, but also for headquarters personnel of these charities, is how to
effectively monitor funds distributed in conflict zones, which can be easily diverted away
from the intended cause. Another challenge for governments which makes charities an
attractive vehicle for terrorist groups is that banned or exposed charities tied to terrorism
can also shut down one day, and reopen the next under a new namea tactic often used
successfully by terrorist organizations.
Charities and NGOs that are tied to terrorist organizations can be and often are quite
open about what theyre doing in terms of fundraising, since it is all ostensibly for humanitarian purposes. Therefore many of the terrorist-linked charities have had websites, openly
advertising their activities and soliciting funds. This includes the Global Relief Foundation
(GRF), an organization designated in 2002 by Treasury for its ties to Al Qaeda and the
Taliban.20 On its website, GRF said that the charity was organized exclusively for charitable, religious, education and scientific purposes including to establish, promote, and carry
out relief and charitable activities, projects, organizations, institutions and funds. GRFs
mission statement focused on its work in emergency relief, medical aid, advancement of
education and development of social welfare, noting that it will act with goodwill towards
all people. GRF accepted donations through its website, with donors able to pay through
credit and debit card, and wire transfers, among other means.21 Another Al Qaedalinked
NGO, the Al-Haramain Islamic Foundation, a Saudi-based NGO that was designated by the
United States in November 2008 for its ties to Al Qaeda, also had a website.22 (A number of
al-Haramains branches had been blacklisted by the United States and by the Saudis years
earlier.)23
Other terrorist organizations also had charitable fronts operating online. These include the Holy Land Foundation, a Texas-based charity, whose leaders were convicted
in 2008 for supporting Hamas. On the site, the Holy Land Foundation outlined their
purported mission, explaining that it was to alleviate suffering through humanitarian
programs helping disadvantaged, disinherited and displaced peoples suffering from manmade and natural disasters.24 The Union of Good (UG), which according to the U.S.
government, is a Hamas front established by the organizations leadership in 2000 to facilitate the transfer of funds to Hamas, also has a website to promote its activities. UGs
English language website was hosted by Interpal, a U.K.-based organization that is a member of UG. Both Interpal and UG have been designated by Treasury25 but continue to
operate.26

Why the Internet?

Terrorists increasing use of the Internet should hardly be surprising, and is being driven
by a number of different underlying factors. First, the use of the Internet has expanded
exponentially over the past decade throughout the world, and terrorists and other illicit
actors use has risen right along side it.27 Currently about 800 million people have access
to Internet, and this will continue to grow in years to comeparticularly in the Middle
East (in 2006, Internet penetration in the Middle was only 8.6 percent, of 16 million).28
Terrorists use of the Internet to raise and transfer funds is also part of a broader global
shift toward the use of technology in international commerce. There have also been dramatic shifts in how funds can be transferred from one destination to another, with new

Downloaded At: 12:41 24 April 2011

Terrorist Financing and the Internet

357

technological developments. Transferring funds electronicallyusing the Internet to initiate transactionshas become increasingly common through such services as PayPal.29
Transactions can also be conducted through cell phones in what are now better known as
M-payments. In countries where the formal financial sector is less than robustsuch
as in many African countriesusing the Internet or cell phones to facilitate transfers is a
far more attractive and readily available option. Online gambling sites and other similar
entities have also made it easier to launder money on the Internet than it was in the pasta
practice that terrorist groups have taken advantage of in recent years. While this type of
activity could potentially expose them to detection, terrorists like Tsouli are able to mask
their identities on the Internet when using these sites.
Terrorist cells involvement in criminal activity is not a phenomenon limited to the
Internet, as they are increasingly engaged in crimes across the spectrum. The primary
reason is that the Al Qaeda core is no longer providing funding to support terrorist cells
and operations. Before 9/11, Al Qaeda funded and controlled operations directly from its
base in Afghanistan. The group provided funding for the East Africa embassy bombings
in 1998, the 2000 attack on the U.S.S. Cole in Yemen, and the September 2001 attacks.
Today, the terrorist threat is far more decentralized, and Al Qaedas central command is
not funding operations as it once did. Left to their own devices, budding terrorist cells have
resorted to criminal activity to raise the funds for attacks.
There are numerous examples of this growing trend. The cell that executed the devastating 2004 Madrid train bombing plot, which killed almost 200 people, partially financed
the attack by selling hashish. The terrorists who carried out the 7 July 2005, attacks on the
transportation system in London were also self-financed, in part through credit card fraud.30
In Southeast Asia, the Al Qaedaaffiliated Jemaah Islamiyah (JI) financed the 2002 Bali
bombings, in part, through jewelry store robberies.31
Another factor that is likely fueling the increase in terrorists criminal activity on
the Internet, is that key terrorist leaders and operatives have specifically encouraged their
followers to pursue this path. For example, Imam Samudra, a former JI operative convicted
for his role in the 2002 Bali bombings, wrote a book during his imprisonment that included
a chapter entitled Hacking, Why Not? In that section of the book, Samudra urged other
jihadists to attack U.S. computer networks, referring to them as vulnerable to credit card
fraud and money laundering.32 While Samudra does not offer specific instructions in the
chapter on how this could be done, he did point readers to specific websites that would help
individuals get started, and to chat rooms where they could find hacking mentors. An
Internet-security training company director said that this would be invaluable to would-be
hackers, noting that this is exactly the kind of advice you would give someone who wanted
to get started in cyber-crime.33
Of particular note, Samudras hacking activities had at least the implicit blessing of
Abu Bakr Bashir, JIs leader, who ruled that hacking into foreigners bank accounts was
religiously permissible, saying that [i]f you can take their blood; then why not take their
property.34 Tsouli tried to encourage others to participate in hacking as well, posting
a Seminar on Hacking Websites, to a popular jihadist forum at one point.35 He also
provided advice on how to mask ones identity on the Internet, so that his fellow jihadists
could avoid detection.36
Perhaps the most obvious reason, however, as to why terrorist groups, cells, and
operatives have increasingly turned to the Internet is for the security it offers. As the United
States and the international community have cracked down on Al Qaeda and affiliated
terrorist organizations, the terrorists have tried to find new ways to avoid detection. The
Tsouli case again provides a good example of the ways in which terrorists are able to exploit

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M. Jacobson

security gaps and opportunities for anonymity that exist on the Internet. Even while he was
engaging in extensive criminal activity on the Internet, Tsouli was able to cover his tracks,
paying for transactions with stolen credit cards and identification information, and never
using his real identity.37 Tsouli also used a variety of techniques to hide his computers
Internet Protocol (IP) address, including anonymizing software and proxy servers.38
In fact, at one point, authorities suspected that Tsouli was in the United States, after
he hacked into and uploaded data to an Arkansas state website and a George Washington
University site.39 Illustrating how seriously Tsouli generally took security matters, he
had never even met Tariq al-Daour, his co-conspirator in this effort.40 Interestingly, in
the end, Tsouli was not caught through cyber-investigation, but through old-fashioned
detective work. In October 2005, Bosnian police arrested two men whom they suspected
were involved in a terrorist attack. In the search of their phone and email records, they
uncovered Tsoulsi and his colleagues.41 Babar was also very careful in his tradecraft,
using aliases and post office boxes to conceal the fact that he was the one operating these
extremist websites, and often paying the fees through cash and money orders. Babar also
used encryption for his email communications as well as to protect data stored in his
computer.42
In fact, terrorists appear so confident about the security that the Internet provides that
many of the terrorist websites are actually hosted by companies in the United States. The
U.S. sites are appealing, experts say, because of the high quality and low costs. There are
numerous examples of websites linked to terrorist groups being hosted by U.S. companies.
For example, a site tied to the Taliban was hosted by a company in Texas, on which the
terrorist group bragged about attacks in Afghanistan on U.S. forces. Perhaps even more
disturbingly, in the 2008 attack in Mumbai, which the Pakistani-based group Laskhar
e-Taiba is suspected of perpetrating, the cell members communicated through Internet
telephone calls, which were routed through a Texas server.43 In at least one case, Hamas
took matters into its own hands, establishing its own Internet Service Provider as part of
its network in the United States. Infocom, which had ties to the Holy Land Foundation,
received some seed money from Hamas leader Abu Mousa Marzook.44 Infocoms leaders
were eventually convicted for violating U.S. export control laws, for providing services to
Libya and Syria.45

Increased Caution for Electronic Payments

Ironically, while terrorist groups have increasingly turned to the Internet to spread their
extremist message in part due to the security and anonymity it offers, they are at the same
time growing more weary about the risks of electronic payments specifically, as governments have begun to crack down. A participant in a recent discussion on al-Fallujah, one of
the well known extremist forums, cautioned others about how they pay for online services.
Governments, this extremist warned, are carefully tracking and monitoring electronic payment services, and through this have been able to identify jihadists and eventually unravel
entire networks.46 The extremist noted that even If your use of the electronic payments has
not brought you woes, then that does not mean it is safe. He recommended that when using
Internet for payment that the brothers use circumvented ways and methods, to make it
more difficult to trace.47 This type of security was only becoming necessary, in the view
of this jihadist, as the governments were becoming increasingly vigilant in monitoring and
tracking electronic transactions.
Hamas has also instructed potential donors on what steps they should take to avoid
getting caught. For example, on its Qassam Brigades website, Hamas told donors to use
fake names when sending e-mails regarding contributions. Hamas also reassured donors

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359

that they will use secure handling for the donations to the fighters. Hizballah, likewise,
has bragged about their sophistication in using the Internet, particularly in using encryption
to protect the communications from detection. Hizballah spokesman Ahmed Jabril said that
with this brilliant encryption, it was possible to send a verse from the Koran, an appeal
for charity and even a call for jihad and know it will not be seen by anyone hostile to our
faith, like the Americans.48

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The Way Forward

Terrorists will continue to exploit the Internet for all aspects of their operations, including
raising and moving funds. This trend is only likely to increase as the scope and scale of the
Internet expands, and with other related technological developments. There is widespread
agreement at this point among governments that the Internet creates serious counterterrorism vulnerabilities, and that action is needed to counter this growing threat. However, there
is far less agreement on what steps need to be taken.
The United States has taken aggressive actions unilaterally in this area, specifically
designed to address the use of the Internet for terrorist financing purposes. This has included
a number of prosecutions of suspected terrorists for their Internet-related activity, including
al-Hussayen and Babar. The United States has also used its law enforcement tools more
broadly, targeting money remitters without adequate anti money laundering/counterterrorist
financing internal compliance systems. The United States has even gone after money
remitters based outside of the United States that were marketing online to U.S. citizens,
charging them with failing to register in the United States, as required by law.49 The
United States has complemented this with a softer approach, reaching out to individual
Internet service providers (ISP) who are hosting troublesome websites, asking these ISPs
to voluntarily shut down the sites. After completing a 60-day comprehensive policy review,
the Obama administration also took a broader step to address the cyber-threat, creating a
Cyber-czar at the White House to coordinate the governments efforts.50
The United Kingdom has been increasingly aggressive as well on this front. Like the
United States, the United Kingdom is reportedly creating a cybercrime coordinator, who will
be located in Whitehall and will lead the governments efforts in this important area.51 The
United Kingdom has also used its law enforcement tools to target those using the Internet
for terrorist purposes. While the Tsouli prosecution was the highest profile case, there have
been others as well. The outcomes have not all been successful, however, demonstrating
what a difficult challenge this is. For example, Sulayman Zainulabin, a London chef who
was offering training courses called the Ultimate Jihad Challenge through his website,
was acquitted of the charges against him.52
Of potential promise, the European Commission is now reportedly moving into this
arena more assertively as well, and will be putting out recommendations that the European
member states increase criminal penalties in cybercrime cases. The Commission may also
press member states to improve cooperation on cyber-investigations, publishing guidelines
on how quickly countries should respond to investigative requests for assistance in these
types of cases. There are currently no time restrictions in place.53
For a variety of reasons, however, not all countries have been as aggressive as the
United States or the United Kingdom on this front. First, many countries lack the technical
capabilities necessary to investigate online terrorist activity. In fact, Interpols Secretary
General stated that the international community needs to increase its efforts in this area 100,
or 1,000 times, if we are serious about combating this threat.54 For example, the United
Arab Emirates (UAE) government is only now learning how to track Internet Protocol

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M. Jacobson

addresses, and more generally, still has only a limited understanding of how to follow the
money. In fact, the UAE has only two analysts in the Dubai police who are responsible
for Counterterrorist Financing (CTF) issuesfar too few to cover this area in the Middle
Easts leading international financial center.55 Second, there is still a debate about how far
governments should go in cracking down on Internet-related activities. Some governments
are concerned that taking these steps will abridge the right to free speech. There is also
an active debate about what works best from a counterterrorism perspectiveparticularly
whether it is more valuable to monitor terrorists activities on the Internet for intelligence
purposes, or to shut them down.
Third, the laws in this area have not kept up with the technological changes, and there
is not agreement about what changes should be made to move forward. At present, there
is no consistency at the national level in what laws are on the books.56 For example, while
in Italy, cyber-cafes are required to ask for identification, Rome is alone in the European
Union in imposing this regulation. In India, some states mandate this, but others do not.57
The United States has also interpreted its responsibilities and laws more expansively than
many other countries, targeting entities outside of the United States for prosecution; others
are hesitant to give their law enforcement agencies this broad, arguably extra-territorial,
reach.
Fourth, while some countries favor the establishment of an international legal instrument or treaty which would govern this area, not all governments regard this as a necessary
or helpful step forward.58 Even the technocratic Financial Action Task Force (FATF), the
Paris-based organization, which aims to set worldwide standards for anti-money laundering/terrorist financing, has been slow to move into this area. While the FATF has identified
the Internet (and particularly Internet payment systems) as a major vulnerability in the
financing arena, it has not put forth comprehensive guidelines for how countries should
mitigate these risks.59 There are still no universally agreed upon thresholds, for example, on
what transactions Internet payment companies are required to maintain recordsan area
where FATF is uniquely qualified to weigh in. These types of records would be particularly
valuable for law enforcement agencies throughout the world as they investigate reports of
terrorist financing activity taking place through the Internet.
And finally, even when countries do decide to act, they will face an uphill challenge.
In response to governmental efforts, terrorists are constantly adapting how they raise and
transfer funds, in an attempt to continue evading detection. New technologies coming on the
scene facilitate the terrorists efforts and complicate governmental tracking efforts. Virtual
currencies available only online that can be used for Internet-based transactions present one
such challenge. Second-life, the biggest virtual economy based in the United States, now
has a market of approximately $500 million annually, which gives a sense of the scale of
these growing businesses. Even more difficult to monitor, from the U.S. perspective, is the
rapidly increasing virtual currency market in China, which is now $800 million a year, and
rising by 30 percent annually.60
Unfortunately, there are limits to what the United States or another other country can
accomplish on its own in this area. The Internet crosses all geographic boundaries, and
if the United States cracks down on what is taking place within its borders, terrorists can
easily relocate to other jurisdictions that are less vigilant about monitoring and countering
this type of illicit activity. Only when there is more of a collective and coherent global
response, will a dent be made in terrorists ability to use the Internet so easily to further
their nefarious goals. The U.S. actions are a step in the right direction, but without broader
international focus and cooperation on this issue, there are real limits to what is likely to
be accomplished.

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Notes
1. Affadavit in Support of Request for Extradition of Babar Ahmad, September 2004 and
indictment of Ahmad in US v. Babar Ahmad, 2004.
2. Affadavit in Support of Request for Extradition of Babar Ahmad, September 2004.
3. Ibid.
4. Ibid.
5. The entire organization was designated in June 2008; many branches of al-Haramain had
been designated years earlier. Treasury press release, Treasury designates Al Haramain Islamic
Foundation, 19 June 2008.
6. Saudi National Charged with Conspiracy to Provide Material Support to Hamas and other
Violent Jihadists, Justice Department Press Release, 4 March 2004. Available at http://www.usdoj.
gov/opa/pr/2004/March/04 crm 137.htm
7. Bob Fink, Idaho Graduate Student Acquitted of Using Internet to Support Terrorism, Associated Press, 11 June 2004. Available at http://seattletimes.nwsource.com/html/localnews/
2001952936 webstudentacquitted10.html
8. Maureen OHagan, A Terrorism Case that Went Awry, Seattle Times, 22 November
2004.
9. Fourth Report of the United Nations 1267 Monitoring Team, January 2006. Available at
http://daccessdds.un.org/doc/UNDOC/GEN/N06/230/45/PDF/N0623045.pdf?OpenElement
10. Jihad Online; Islamic Terrorists and the Internet, Anti-Defamation League, 2002.
11. Office of the Director of National Intelligence, Declassified Key Judgments of the National
Intelligence Estimate Trends in Global Terrorism: Implications for the United States Dated April
2006. Available at http://www.dni.gov/press releases/Declassified NIE Key Judgments.pdf
12. Gordon Corera, The Worlds Most Wanted Cyber-Jihadist, BBC News, 16 January 2008.
13. Ibid.
14. Cyber Operative Charged in Real World Terror Plot, Anti Defamation League, 1 March
2006.
15. See US Secret Service press release. Available at http://www.secretservice.gov/
press/pub2304.pdf. These forums obtained the credit cards through various online scams and e-mail
viruses. Brian Krebs, Terrorisms Hook into Your Inbox, Washington Post, 5 July 2007.
16. For example, one New Jersey woman described how she received an e-mail asking for her
to verify eBay account information, which she completed, including sensitive financial information.
Al-Daour ended up with her credit card information. Krebs, Terrorisms Hook into Your Inbox.
17. Ibid.
18. Written statement of Andy Cochran, Congressional Hearing, 31 March 2009, For the Subcommittee on Emerging Threats, Cybersecurity, and Science and Technology Hearing, U.S. House
Committee on Homeland Security, Do the Payment Card Industry Data Standards Reduce Cybercrime? Interestingly, Tsoulis terrorist activities went beyond financial, to other types of logistical
support. Of particular concern to U.S. authorities, British investigators discovered casing videos
of targets in the United States, including various landmarks in the Washington, DC area. They
were allegedly shot by two individuals living in the Atlanta, Georgia area. John Murgatroyd, Two
Views of Former Georgia Tech Student Drawn at Terror Trial, CNN, 2 June 2009. Available at
http://www.cnn.com/2009/CRIME/06/02/georgia.jihad.trial/
19. Financial Action Task Force, Terrorist Financing, 29 February 2008. Available at
http://www.fatf-gafi.org/dataoecd/28/43/40285899.pdf, p. 11.
20. Treasury press release, Treasury Department Statement Regarding the Designation of the
Global Relief Foundation, 18 October 2002. http://www.ustreas.gov/press/releases/po3553.htm
21. Jihad Online; Islamic Terrorists and the Internet.
22. Treasury designation of al-Haramain as an organization, 19 June 2008. Available at http://
www.ustreas.gov/press/releases/hp1043.htm
23. Treasury press release, 2 June 2004. Available at http://www.treas.gov/press/releases/
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24. Jihad Online; Islamic Terrorists and the Intenet.

25. Treasury designation of Interpal, 22 August 2003. Available at http://www.ustreas.gov/
press/releases/js672.htm; Union of Good designation, 12 November 2008. Available at http://www.
treas.gov/press/releases/hp1267.htm
26. Steve Merley, The Union of Good: Interpal and the UK Member Organizations,
NEFA Foundation, 23 March 2009. http://www.nefafoundation.org/miscellaneous/FeaturedDocs/
nefaunionofgoodmemberorgs0309.pdf
27. Terrorists are also far from alone in using the Internet for illicit purposes. In fact, crime
on the Internet has been growing rapidly, with the FBI estimating losses from Internet crime in
2008 at approximately $264 million. The agency received 275,000 such complaints from the public in that year alone. FBI press release, 30 March 2009. Available at http://www.fbi.gov/page2/
march09/internet 033009.html
28. Fourth Report of the United Nations 1267 Monitoring Team.
29. Its important to note that the funds themselves would not actually be transferred through
the Internet. The communication channel would instruct a service provider on what action to take.
30. David Aufhauser, Testimony Before the House Financial Services Oversight Committee,
18 May 2004. http://financialservices.house.gov/media/pdf/051804da.pdf
31. David Kaplan, Paying for Terror: How Jihadist Groups are using Organized-Crime
Tacticsand Profitsto Finance Attacks on Targets around the Globe, U.S. News and World
Report, 27 November 2005. Available at http://www.usnews.com/usnews/news/articles/051205/
5terror print.htm
32. Written statement of Andy Cochran, Congressional Hearing.
33. Alan Sipress, An Indonesians Prison Memoir Takes Holy War into Cyberspace, Washington Post, 14 December 2004.
34. Irhaby 007s American Connections, NEFA Foundation, January 2008, citing Kaplan,
Paying for Terror.
35. Rita Katz and Michael Kern, Terrorist 007, Exposed, The Washington Post, 26 March
2006.
36. Nadya Labi, Jihad 2.0, The Atlantic Monthly, July/August 2006. This was apparently
something Tsouli learned early in his Internet career. When he first began visiting a particular jihadist
site, one of the members of the forum warned Tsouli not to access the site from his own IP addressa
lesson Tsouli appears to have generally heeded.
37. Written statement of Andy Cochran, Congressional Hearing.
38. Labi, Jihad 2.0.
39. Katz and Kern, Terrorist 007, Exposed.
40. Corera, The Worlds Most Wanted Cyber-Jihadist. Although Tsouli was extremely careless on several occasions, failing to anonymize his transactions, which led one private cyberinvestigator to conclude that Tsouli was located in Ealing, Englanda short distance from his
actual home. Labi, Jihad 2.0.
41. Cyber Operative Charged in Real World Terror Plot, Anti Defamation League, 1 March
2006. http://www.adl.org/main Terrorism/terrorist 077 younis tsouli.htm
42. Indictment of Babar Ahmed, and Affadavit in Support of Extradition.
43. Joby Warrick and Candace Rondeauz, Extremist Web Sites are Using US hosts, Washington Post, 9 April 2009.
44. Justice Department press release, 13 October 2006. Available at http://www.usdoj.gov/
usao/txn/PressRel06/elashi bayan ghassan basman infocom sent pr.html
45. Ibid.
46. Jihadi Discussion Forum Posting on Safely Financing Jihad-Related Websites, Translated
by NEFA Foundation, 7 April 2009. http://www.nefafoundation.org/miscellaneous/FeaturedDocs/
nefafinancejihadsites0409.pdf
47. Ibid.
48. Jihad Online; Islamic Terrorists and the Internet.

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49. See, for example, the U.S. Justice Department prosecutions of MENAEXCHANGE.com, a
money remitter that transferred funds between the United States, the Middle East, and North Africa.
50. Bonnie Johnson, Obama to Create Cybersecurity Chief, The Guardian, 29 May 2009.
Available at http://www.guardian.co.uk/technology/2009/may/29/obama-cybersecurity
51. Chris Williams, UK.gov to Create Central Cybersecurity Agency, The Register, 15 June
2009. Available at http://www.theregister.co.uk/2009/06/15/cabinet office cybersec agency/
52. Chef to Sue over Terror Charges, BBC, 13 August 2002. The British have been more
successful in other Internet-related cases. According to British authorities, an Al Qaedaassociated
individual in the United Kingdom was using multiple identities to finance the purchase and supply of
explosives components for use in another country. Forensic financial investigation revealed that this
person used multiple accounts to purchase high resolution maps of a third country over the Internet.
Following the money enabled investigators to track the international travel of the conspirators as well
as the delivery by international courier of components for improvised explosives to the same foreign
country over several months. Multiple transactions involving accounts controlled by an associate of
the original suspect revealed a wider conspiracy. In a joint operation with a foreign law enforcement
agency, the original suspect was tracked to a third country where he was arrested in a makeshift bomb
factory. HM Treasury, Foreign and Commonwealth Office, Government of the United Kingdom,
The Financial Challenge to Crime and Terrorism, February 2007. Available at http://www.hmtreasury.gov.uk/media/C/B/financialchallenge crime 280207.pdf.
53. Jeremy Kirk, Europe Looks to Step Up Fights against Cybercrime, PC World,
10 June 2009. Available at http://www.pcworld.com/article/166420/europe looks to step up
fight against cybercrime.html
54. Terrorist Use of the Internet: Threat, Issues, and Options for International Cooperation,
Rapahel Perl, OSCE, 710 April 2008, at the Second International Forum on Information Security.
55. Interview with State Department official, January 2008.
56. Terrorist Use of the Internet.
57. Indian States Make Cyber-Users Sign in, Fox News, 10 January 2006. Available at
http://www.foxnews.com/story/0,2933,181221,00.html
58. For example, at an April 2009 conference in Spain organized by the Council of Europe and
the Organization of American States that the author attended, the Russian Federation was pressing
for an international treaty to govern this area, but the United States and others pushed back against
the Russian proposals. The U.S. position is that the focus should be on improving the implementation
of the Council of Europes September 2001 Cyber-crime treaty.
59. FATF Report, entitled, Money Laundering and Terrorist Financing: Vulnerabilities of
Commercial Websites, and Internet Payment Systems, 18 June 2008. Available at http://www.fatfgafi.org/dataoecd/57/21/40997818.pdf
60. Olga Kharif, Virtual Currencies Gain in Popularity, Business Week, 6 May 2009.